REACH, Rolls-Royce & the Supply Chain

REACH, Rolls-Royce & the Supply Chain
Cathy Phillips, HS&E Materials Rolls-Royce Group

Rolls-Royce today A global business £24bn order book
£6.6bn annual sales £663m R&D 36,000 employees 7,600 engineers Supporting four market sectors Civil Defence Marine Energy October 2007 © Rolls-Royce Plc

REACH, Rolls-Royce & the Supply Chain
What REACH means to Rolls-Royce Issues we foresee within the supply chain What Rolls-Royce is doing to prepare for implementation – within the company Managing the supply chain issues Summary October 2007 © Rolls-Royce Plc

What REACH means to Rolls-Royce
Rolls-Royce as an importer Alloys are preparations (bar, billet, specialist metallic powders etc) Processing chemicals (drums of liquid and powder preparations etc) Importing finished articles (with no intended substance release) October 2007 © Rolls-Royce Plc

Rolls-Royce as an importer Rolls-Royce will have to be involved in pre-registration/registration if we import > 1 tonne of a substance (which could be in several imported preparations). Contracts on non-EU suppliers will have to change to obtain information to complete registration. October 2007 © Rolls-Royce Plc

Rolls-Royce as a downstream user Making articles out of preparations, and using preparations / substances during manufacture Making some preparations (eg thermal paints) Conducting Product and Process Oriented Research and Development (PPORD) with suppliers October 2007 © Rolls-Royce Plc

Rolls-Royce as a downstream user Check whether SVHCs are in products following manufacture, at > 0.1% w/w Check all our uses are registered Substances used in PPORD will require notification to the Agency, and will probably avoid SVHCs (including candidate substances) October 2007 © Rolls-Royce Plc

Rolls-Royce as a downstream user Using the new extended safety data sheets Legal requirement to use the RMM specified Too restrictive… write own CSR Too vague… write own CSR Two suppliers, 2 different RMMs? REACH RMM ‘Library?’ October 2007 © Rolls-Royce Plc

Rolls-Royce as a user of substances of very high concern (SVHC) Using SVHCs within alloys, within process chemicals – and unable to change quickly to alternatives (in some cases, there may be no alternatives) October 2007 © Rolls-Royce Plc

Rolls-Royce as a user of substances of very high concern (SVHC) Rolls-Royce specifiers, purchasers, designers and technical experts will need to work with customers (who may specify SVHC use) and suppliers (who may have a technical necessity to use SVHC) to prove the need for each SVHC within any Authorisation. October 2007 © Rolls-Royce Plc

Example: Trichloroethylene Trichloroethylene is a CMR which is very likely to be subject to Authorisation sooner rather than later. Industry Response: STOP supplying to companies with open topped / lidded degreasers from 2010. MSDS Risk Management Measures will require totally enclosed degreasers with no release Collaboration on socioeconomic analysis for Authorisation Significant cost increases will occur Effect: We must continue to try to find safer alternatives- and use only as a last resort October 2007 © Rolls-Royce Plc

October 2007 © Rolls-Royce Plc

Issues within the supply chain
Changing formulations Could invalidate aircraft safety certification (European Aircraft Safety Agency, EASA) Withdrawal of formulation Need to find and prove alternatives to satisfy certification requirements October 2007 © Rolls-Royce Plc

Lack of information about substances in formulations Unable to check that formulation is being used legally Lack of information about substances in dried coatings / adhesives etc. Unable to meet legal obligations to provide information on SVHCs to customers October 2007 © Rolls-Royce Plc

Too specific or too general information on uses in the Chemical Safety Report Checking that substances are being used legally will be a laborious exercise Failure to register / Failure to check that the substance is being registered for their use Substance could be lost due to supplier failure to engage in the REACH registration process for their use of a substance. October 2007 © Rolls-Royce Plc

Business Risks and REACH
REACH could result in some of the substances used to make manufactured products being: Unavailable, if suppliers (manufacturers / importers) do not register the substances. Increasingly difficult to obtain in the long term, if they are hazardous. More costly to buy (because of the registration and authorisation costs). REACH is a Supply Challenge Substance obsolescence Product availability Knock-on effect on Prices Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements) October 2007 © Rolls-Royce Plc

REACH will have BENEFITS for human health, and the environment because some really hazardous chemicals in use on their sites will not be allowed in future. More information will be available about the hazards and how to manage them (on the SDS) Most risk assessments will be easier to put together and to audit against – Users are required to follow the Risk Management Measures on the SDS REACH is a Supply Challenge Substance obsolescence Product availability Knock-on effect on Prices Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements) October 2007 © Rolls-Royce Plc

BUT If you have an unusual use for a chemical, you will have to complete MUCH MORE paperwork (such as convince the supplier to add your use, or failing that, write a Downstream User’s “chemical safety report”) There are very likely to be obsolescence issues for consumables, components, tools and products. REACH is a Supply Challenge Substance obsolescence Product availability Knock-on effect on Prices Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements) October 2007 © Rolls-Royce Plc

SO… It can – if not managed well – be a business continuity issue. It can be a compliance issue So REACH is NOT “just another HSE issue”. It is a purchasing, manufacturing, design and strategic issue that just happens to originate in the field of HSE. REACH is a Supply Challenge Substance obsolescence Product availability Knock-on effect on Prices Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements) October 2007 © Rolls-Royce Plc

Getting organised internally
Workshops for key stakeholders Workshop for HS&E Practitioners, Purchasing, Engineering, Chemists… Workshop for Vice Presidents and Directors Workshop for the business in North America Plans for supply chain workshops with ASD / SBAC Creating an implementation plan Planning to establish an Integrated Project Team (IPT) at a corporate level and subsidiary IPTs for each of the most affected businesses October 2007 © Rolls-Royce Plc

Managing the Issues: Collaboration
The Aerospace sector globally is now working on several initiatives: ARTICLES interpretation Standard data to be collected from suppliers for REACH Common guidelines for our sector(s) Supporting trade association / professional institution workshops on REACH Sharing best practice across sectors Working with DEFRA and HSE ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Helping our Supply Chains Understand REACH
REACH guide for our industry The REACH Guide is available on CD-Rom and Leaflet October 2007 © Rolls-Royce Plc

Helping aviation businesses understand REACH
Banned / Targeted list of substances To be used by companies for forward planning OEMs can target B/T list substances for phase out EARLY – ‘Future-Proofing’ our industry Banned / Targeted list Substances of very high concern = candidates to authorisation Known SVHC Annex XIV = substances submitted to authorisation Priority SVHC Newly Classified SVHC ALL REGISTERED SUBSTANCES October 2007 © Rolls-Royce Plc

The Banned / Targeted List
Anticipating possible obsolescence and required R & T October 2007 © Rolls-Royce Plc

Managing the supply chain issues
Understanding the requirements (RIPs) Involvement is shared across ASD members (Airbus, Eurocopter, Rolls-Royce, SAAB, Volvo Aerospace etc.) Developing case studies for RIP 3.9 Socio-Economic Analysis RIP 3.8 Articles requirements RIP 3.5 Downstream Users October 2007 © Rolls-Royce Plc

Getting the information flowing: ‘Notice to Suppliers’ (NTS198, ) on Rolls-Royce suppliermanager-online website (more information to follow) Trade body discussions and collaboration Identifying contacts in registration consortia for strategically important substances Presentations to suppliers and other companies, sharing REACH approaches October 2007 © Rolls-Royce Plc

Continuing supply of compliant products Changing specifications on suppliers Advising suppliers which parts to change, and to change certain processes to avoid SVHCs Obtaining EASA certification for and approving for use, new alternatives and changing Rolls-Royce materials and process specifications to fit these new substances Anticipating involvement in changing internationally used material specifications etc. October 2007 © Rolls-Royce Plc

Working With the European Commission and ECHA
Various companies across ASD, SBAC and GIFAS are representing our sector in REACH IMPLEMENTATION PROJECTS (RIPs) The RIPs will generate TECHNICAL GUIDANCE DOCUMENTS (TGDs) to help businesses find their way through the legal maze October 2007 © Rolls-Royce Plc

Practical Steps to Implementing REACH – What have we got to do?
REACH requires different areas (Purchasing, Engineering and Design, Manufacturing operations and HSE), to work together inside our companies (easy for SMEs!). REACH will require new information to be collected within companies, and to be passed up and down supply chains (NOT easy for SMEs!). REACH is a Communication Challenge Require strong Management: To involve all parts of a business (consultation, task project plan) To control efficiently the data about chemicals and products (Database – 10 years storage) To ensure good communication process with suppliers and customers October 2007 © Rolls-Royce Plc

Step 1: The end of ignorance
What should you do about it? Most of your supply chain is probably ignorant about REACH. Your senior managers are probably ignorant about REACH. If you want to maintain access to chemicals & raw materials, you need to get other departments to take on the implementation of REACH So first you need to brief senior managers and then brief your top suppliers. ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Step 2: Get resource and plan
Start developing the action plan Find out: What is imported Collating the information on how much is imported (looking at purchase orders over the past 3 years) What is not imported, but is still strategically important Checking that the supply chain are going to meet their obligations for registration ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Step 3: build an material inventory
Make a list of all the materials used by your business, if you do not already have a list: Your PURCHASING people need to find out… The tradenames / specs of the chemicals you buy Where and who you buy them from (import?) How much you buy ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Your LABS / MATERIALS People need to find out… The substances in each of the materials (EINECs/ELINCS/CAS numbers) Is it vital to your product or to a manufacturing process? ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

You will need to identify, for each Tradename / specification / constituent inside the preparation… Is it hazardous? (CMR, PBT, vPvB) – COSHH Inventories What is your business risk (will the supplier register it or will you have to?) ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Step 4: turn the materials inventory into a substance inventory
SOMEONE (You? Purchasing? Labs?) needs to… Rearrange all the data you have by tradename / specification to be listed by substance Check that each substance has either an EINECs or ELINCs number (if not – this is very bad) Sum the amount of each substance you have bought in 2005,2006,2007 and average it. This is where off-the-shelf REACH software could really help… ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Step 5: Decide what to pre-register
If you are an importer of >1tonne or more, you have to pre-register. If you MANUFACTURE SUBSTANCES you have to pre-register. If the substance is strategically vital and your supplier will not guarantee they will pre-register / register, you may choose to either: Find a supplier who will do it for you Preregister it yourself to minimise your business risk… ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Step 6: Pre-register (by 30 Nov 2008)
There is lots of work involved in registering. Consider sharing a ‘Third Party Representative’ The Data and Information Technology issues: Download IUCLID 5 software (its free) from the ECHA website Fill it in with the basic information – which tonnage band, the EINECs number, your company details, SVHCs etc. Set up an address just to deal with the information from pre-registration. ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Step 7: SVHCs in PREPARATIONS
Cross reference your substance inventories to your COSHH database / MSDS information looking for CMRs, vPvBs and PBTs (these could become SVHCs on the ‘candidate list’, and then added to Annex 14). Are any of these substances ‘strategically important?’ Would you have unhappy customers if you changed? ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Step 8: SVHCs in Articles
You may buy articles and incorporate them in your product and you might make articles: Both could have SVHCs. You need to know HOW MUCH of WHICH SVHC is in each article you buy… Only then can you work out if what you sell has > 0.1% weight by weight in YOUR product. Then you have to NOTIFY the agency and customers (Articles 7(2), Article 33). ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Step 9: Planning for Authorisation
vPvBs and PBTs with wide dispersive use will probably be subject to authorization first and MAY need registering, even below 1 tonne (but not yet!) Check whether you REALLY NEED to use the potential SVHC substance. REACH will change cost/benefit arguments. Your suppliers may soon be placing requirements on you! (Trichloroethylene…!) ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

Step 9: Planning for Authorisation
Monitor Annex 14 and the Candidate list for the substances you use. Where you have identified that you will be unable to easily move away from using a candidate list / Annex 14 substance, Contact others in your industry in the same boat. Talk to any industrial customers about the issue. Find out the supplier’s plans for Authorization. Start looking into alternatives (Align R&D programs). Authorization will start circa mid 2009. Get planning for it now! ASD: AeroSpace and Defense Industries Association of Europe Large Companies: Aeronautical (Airbus, Smith Aerospace, Eurocopter…) Automotive (Volvo, Renault…) CBI: Confederation of British Industry October 2007 © Rolls-Royce Plc

In Summary There is loads to do, within the company and within the supply chain, in a fairly short time frame. A mass of information needs to flow up and down supply chains for REACH. We are collaborating and intend to help our industry and our supply chain deal with REACH as cost-effectively as possible. If you supply to the aviation industry in the UK / EU expect to see contract changes, requests for information and sector specific REACH workshops as we get organised for REACH. October 2007 © Rolls-Royce Plc

REACH, Rolls-Royce & the Supply Chain

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